## Facts

- A joint labor-management committee (JATC) administered a four-year carpentry apprenticeship program in Northern California under a trust agreement giving it authority to structure the program and select apprentices.
- Applicants had to meet basic entry criteria, be placed on a “new applicant referral list,” and satisfy a first-job requirement by obtaining employment with a union contractor.
- Applicants could satisfy the first-job requirement either through (1) contractor requests filled in numerical order off the referral list, or (2) a “hunting license” that allowed applicants to solicit contractors directly and be hired by name regardless of list position.
- The hunting-license method was the dominant route into apprenticeships; reliance on numerical dispatch from the referral list was largely ineffective.
- Female applicants brought a Title VII action alleging sex discrimination in access to apprenticeships, including a claim that the hunting-license system had a discriminatory effect because employers tended to hand-pick men.
- The district court ordered joinder of thousands of employers and dozens of union locals as indispensable parties under Federal Rule of Civil Procedure 19 and dismissed when joinder was not feasible.

## Issues

1. Whether employers and union locals participating in collective-bargaining arrangements were indispensable parties under Rule 19 such that a Title VII challenge to the apprenticeship selection/referral system had to be dismissed absent their joinder.
2. Whether complete relief and effective remedial orders could be provided in an action proceeding solely against JATC as the administrator of the challenged system.

## Decision

- The Ninth Circuit reversed the dismissal and remanded.
- The court held the district court misapplied Rule 19 by treating the employers and union locals as indispensable parties.
- The action could proceed against JATC alone because the challenged practices were tied to JATC’s control over the apprenticeship structure and selection process.
- The Supreme Court denied certiorari; Justice Rehnquist dissented from the denial.

## Legal Principles

- Rule 19 does not require joinder of all third parties who participate in an employment system when the plaintiff seeks relief directed at the institutional actor responsible for designing or administering the challenged structure.
- Parties are not “indispensable” where the court can accord complete relief among existing parties and shape effective injunctive or structural remedies against the defendant before the court.
- An entity with authority over an apprenticeship program’s admission framework may be a proper Title VII defendant even if discriminatory outcomes are alleged to occur through hiring choices made by participating employers.

## Conclusion

The Ninth Circuit held that a Title VII challenge to an apprenticeship program’s selection and referral structure was not subject to dismissal under Rule 19 merely because many employers and union locals participated in the system; because JATC controlled the program’s structure and could implement court-ordered remedies, the case could proceed against JATC without joining those third parties.


Eldredge v. Carpenters 46 N. Cal. Cntys. Joint Apprenticeship & Training Comm., 662 F.2d 534 (9th Cir. 1981), cert. denied, 459 U.S. 917 (1982)